Atkins v. Rivera
In Atkins v. Rivera, 477 U.S. 154, 106 S.Ct. 2456, 91 L.Ed.2d 131 (1986), the Court traced the history of 42 U.S.C. Sec. 1396a(a)(10)(c)(i)(III) and held, "the 'same methodology' requirement simply instructs states to treat components of income--e.g. interest or court ordered support payments--similarly for both medically and categorically needy persons." Atkins v. Rivera, 106 S.Ct. at 2462.
The Court observed that Congress enacted the "same methodology" requirement to invalidate regulations promulgated by the Secretary in 1981 that allowed states to use different income and resource criteria when determining the eligibility of medically and categorically needy persons. Id. at 2462-63 & n. 10.